Compliance Compass: update on data match
League Regulatory Counsel
In June, The League urged credit unions to
wait to sign an agreement with the Wisconsin Department of
Workforce Development for data matching.
Since then, at the urging of The League
and other interested stakeholders, the DWD has agreed to change the
terms of its new Unemployment Insurance Financial Record Match
The League has withdrawn its objections to the
new contract; however, credit unions must understand the consequences of
choosing between the two options for conducting data matches.
It appears that most credit unions opt to send
data to the state for conducting other mandated matches. Credit unions
that instead choose to do the matches themselves need to understand that
they are agreeing to some burdensome contract provisions.